CLA-2-94:OT:RR:NC:N4:463
Doug Peck
Brown Jordan Company, LLC
401 Frederick Road
El Paso, TX 79905
RE: The classification of two coffee tables and three dining tables from Mexico
Dear Mr. Peck:
This ruling is being issued in response to your letter dated April 4, 2025, requesting a tariff classification
determination two coffee tables and three dining tables. In lieu of samples, pictures and product descriptions
were provided.
The Adapt 30" x 60" Coffee Table, SKU number 5634-3060-FS, is a low rectangular table, measuring 60"
(L) x 30" (W) x 13" (H). The table base and four legs (one at each corner) are made of aluminum, and it has
a tabletop made of Dekton. See image below:
The H 45" Round Coffee Table, SKU number 5574-4500, is a low round table measuring 45" (L) x 45" (W)
x 14" (H). The table base and three table legs are made of aluminum, and it has a tabletop made of Dekton.
See image below:
The Parkway 54" Round Dining Table, Glass Umbrella Top, SKU number 3476-5400, is a round patio table
measuring 58" (L) x 58" (w) 28.5" (H). The table base and four table legs are made of aluminum, and it has a
tabletop made of glass with a center hole for the placement of an umbrella. See image below:
The Trentino Dining Table 40" x 100", SKU number 5701-4010, is a rectangular table measuring 40" (L) x
110" (W) x 29" (H). The table base and four table legs are made of aluminum, and it has a tabletop made of
Dekton. See image below:
The Adapt 36" x 96" Rectangular Dining Table Wood, SKU number 5631-3696-TK, is a rectangular table
measuring 96" (L) x 36" (W) x 28.75" (H). The table base and four table legs (one at each corner) are made
of aluminum, and it has a tabletop made of teak. See image below:
The tables are made in Mexico.
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance
with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be
determined according to the terms of the headings of the tariff schedule and any relative section or chapter
notes. If the goods cannot be classified solely based on GRI 1, and if the headings and legal notes do not
otherwise require, the remaining GRIs 2 through 6 may then be applied in order.
In understanding the language of the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity
Description and coding System, which constitutes the official interpretation of the Harmonized System at the
international level, may be utilized. The ENs, although not dispositive or legally binding, provide a
commentary on the scope of each heading and are generally indicative of the proper interpretation of the
HTSUS. The ENs to Chapter 94 of the HTSUS state, in relevant part, for the purposes of this Chapter, that
the term “furniture” means: (A): Any “movable” articles (not included under other more specific headings of
the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or
ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres,
cinemas, offices, churches, schools, cafés, restaurants, laboratories, hospitals, dentists, surgeries, etc., or
ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. The subject
tables are within the meaning of furniture as described by the General ENs to Chapter 94 of the HTSUS.
Because the articles are composed of different materials (aluminum, glass, etc.), they are considered
composite goods for tariff purposes. The ENs to the HTSUS, GRI 3(b) (VIII) state that “the factor which
determines essential character will vary between different kinds of goods. It may, for example, be
determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of
a constituent material in relation to the use of the goods.” When the essential character of a composite good
can be determined, the whole product is classified as if it consisted only of the material or component that
imparts the essential character to the composite good.
Barring significant evidence to the contrary with respect to the classification of tables, U.S. Customs and
Border Protection (CBP) has historically found that the material comprising the tabletop imparts the essential
character. (See NYRLs N315828 and N334127.) These tables are no exception. The tabletop materials
provide these tables with their functionality.
Accordingly, the applicable classification for Adapt 30" x 60" Coffee Table, SKU number 5634-3060-FS, the
H 45" Round Coffee Table, SKU number 5574-4500, the Parkway 54" Round Dining Table, Glass Umbrella
Top, SKU number 3476-5400, and the Trentino Dining Table 40" x 110", SKU number 5701-4010 will be
subheading 9403.89.6015, HTSUS, which provides for “Other furniture and parts thereof: Furniture of other
materials, including cane, osier, bamboo or similar materials: Other: Other: Other household.” The general
rate of duty will be free.
The applicable classification for the Adapt 36" x 96" Rectangular Dining Table Wood, SKU number
5631-3696-TK, will be subheading 9403.60.8040, HTSUS, which provides for “Other furniture and parts
thereof: Other wooden furniture: Other: Dining tables.” The rate of duty will be free.
Products of Mexico as provided by heading 9903.01.01 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(a), HTSUS, other than products classifiable under headings 9903.01.02, 9903.01.03, 9903.01.04, and
9903.01.05, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry,
you must report the applicable Chapter 99 heading, i.e. 9903.01.01, in addition to subheading 9403.60.8040
and 9403.89.6015, HTSUS, listed above. Articles that are entered free of duty under the terms of general
note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in
subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the
additional ad valorem duties provided for in heading 9903.01.01. If your product is entered duty free as
originating under the USMCA, you must report heading 9903.01.04, HTSUS, in addition to subheading
9403.60.8040 and 9403.89.6015.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS
and the accompanying duty rates are provided on the internet at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request.? This position is set forth in Title 19, Code of Federal Regulations (CFR),
Section 177.9(b)(1).? This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect.? If the facts are modified in any way, or if the goods do not conform to
these facts at the time of importation, you should bring this to the attention of CBP and submit a request for a
new ruling in accordance with 19 CFR 177.2.? Additionally, we note that the material facts described in the
foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of Title 19 of the Code of Federal Regulations
(19 CFR Part 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported.? If you have any questions regarding the ruling, contact
National Import Specialist Seth Mazze at [email protected]
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division